This policy is divided into the following sections:
Who we are and how to contact us
Our collection and use of your personal information
Who we share your personal information with
How we securely store your information and for how long
Your Data Protection Rights
Transfers of your information out of the UK and EEA
Links to other website
Who we are and how to contact us
This website is operated by Bruntwood Management Services Limited (‘Bruntwood’)
Bruntwood are committed to offering more than just outstanding office, coworking or retail and leisure space. Everything we do is tied into our vision of building vibrant places, whilst providing businesses and communities with the support and expertise they need to grow and thrive. Our places are people driven, design led and socially responsible.
Bruntwood believes in sustainable cities for people to work and live; each year together with the Oglesby Charitable Trust donating 10% of distributable profits to local arts and cultural good causes.
Address: Union, 2-10 Albert Square, Manchester M2 6LW Phone Number: 0333 323 2237
Please mark the envelope ‘Data Protection Manager’.
We are committed to protecting and respecting your privacy.
We collect, use and are responsible for personal information we process about you. We act as ‘controller’ of that personal information under data protection legislation in the UK, including the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 and we adhere to the obligations set out in the data protection legislation in relation to our processing of your personal data.
Our collection and use of your personal information
Under data protection legislation, we are required to explain what information we collect from you and how and why we use your personal information (the “processing activity”). We are also required to have a “lawful basis” on which to process your personal information, as further detailed below.
What type of information we collect
We currently collect and process the following information:
Personal identifiers, contacts and characteristics (for example, name and contact details)
Information about your devices, such as IP addresses
How you browse our websites
Details of the products or services you purchase
Financial information (for example credit card details, bank account numbers).
Photography and videography (through CCTV and other systems);
Building access systems;
Call recordings (when you ring our call centre or we ring you).
How we get the information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
You have enquired about a product/service from us.
You have purchased a product/service from us.
You have provided contact details to us for customer service purposes.
You have spoken to us by telephone and we have recorded the call and/or collected your phone number from you personally during that call or digitally. Where call recording facilities are being used we will inform the caller via a recorded message which is played prior to connection to an operator in the call centre.
You have made contact with us via one of our social networks.
You wish to attend, or have attended, an event.
You have agreed to participate in a photo/video shoot.
You have subscribed to newsletters.
You have joined our online customer community.
You have visited our website.
You have visited one of our buildings.
You have entered a competition or taken advantage or a promotional offer.
You have applied for a job with us.
An employee of ours has given your contact details as an emergency contact or referee.
We also receive personal information indirectly, from the following sources in the following scenarios:
Sometimes we obtain information about you from third parties such as marketing agencies or other members of the other affiliated Bruntwood companies. The data these companies might hold on you is collected from public sources, such as Companies House, or from other sources where you have agreed for your information to be shared with third parties or where it is in our legitimate interest to contact you.
We may also match your cookie data with third party data such as Google and social media platforms.
We can also access information from social media activity such as when you ‘like’ a post, share content or follow us.
Your employer has provided it to us for building access purposes.
This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.
Legal Basis for Processing
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on includes:
Your consent: where you have given us clear consent for us to process your personal information for a specific purpose You are able to remove your consent at any time. You can do this by contacting GDPR@bruntwood.co.uk
We have a contractual obligation: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
We have a legitimate interest: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)
We have a vital interest: where our use of your personal information is necessary to protect you or someone else’s life.
We have a legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).
What we do with the information we have
We use the information that you have given us in order to:
Provide you with relevant information about a product or service you have enquired about.
Process legal documentation and financial information in relation to a purchase you have made or contract you have with us.
Respond to any customer service requests.
When you call our contact centre, including information about complaints and services, we monitor and/or record calls between our staff and you for the purposes of resolving complaints, training and to improve our quality and service standard. Where you are a representative of a business we may also use information collected from you to contact you for marketing purposes, unless you have opted out.
Manage attendance at events.
Produce marketing collateral and communications if you have agreed to participate by signing a release form or by not opting out at an event.
Informing you about news, events, products, services or promotional offers that you might find interesting if you have chosen to receive these types of communications or where we are processing that data on the basis of legitimate interests, where you have not opted out
Improving the design, style and functionality of the website.
Dealing with, and responding to you about, any comments and engagements we have had from you via our social media channels
Manage security and access to our buildings and premises (for example through the use of CCTV, access entry systems or other processes);
Manage compliance with our policies and procedures;
To protect the security of our systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
To help us recover debts;
To help us improve the quality of our solutions and services;
For general administration purposes;
To review your CV as to suitability for a role, and as part of our recruitment process;
Share the information with our group and third parties for the purposes set out in this policy;
For purposes required by law, including maintaining records, compliance, legal screening and compliance (e.g. anti-money launders, credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws) to include identification checks.
We may share this information with:
Other members of the other affiliated Bruntwood companies.
Our contracted service providers that process personal information on our behalf for IT and system administration and hosting, credit card processing, billing, research and analytics, marketing, customer support and data enrichment. Only companies who can provide adequate safeguards will be used to ensure your data is stored and handled securely.
We will also disclose your personal information to third parties:
In the event that we consider selling or buying any business or assets, in which case we will disclose your personal information to any prospective sellers or buyers of such business or assets;
In the event we are the subject of any insolvency situation (e.g. the administration or liquidation);
Administering competitions/promotional offers and informing you if you have been successful.
Compiling customer feedback.
Conducting market research.
Dealing with any query or complaint you submit to our customer experience team.
Ensure the safety and security of everyone in our buildings.
Processing job applications.
Third party social media and advertising networks so that we can advertise on their platforms.
Professional advisers who provide consultancy, banking, legal, insurance and accounting services.
Exchanging information with other companies and organisations (including without limitation HMRC, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction
Public and government authorities and fraud prevention agencies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters;
If we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; and in order to enforce or apply our terms and conditions.
How we store your information and for how long
Your information is securely stored by Bruntwood.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We keep your personal information for as long as necessary in accordance with our purpose of processing and legal basis and thereafter in accordance with data protection law. We will then securely dispose of your information. If you require further information in relation to our specific retention periods, please contact us at GDPR@bruntwood.co.uk.
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights, save where we are permitted to do so due to a request being manifestly unfounded or excessive or where you require extra copies of information. If you make a request, we have one month to respond to you.
Please contact us at GDPR@bruntwood.co.uk or by post at Bruntwood, Union, 2-10 Albert Square, Manchester M2 6LW if you wish to make a request.
Transfer of your information out of the UK and EEA
We may transfer personal information to countries other than the country in which the data was originally collected (for example, outside the UK/EEA) in order to provide you with our services. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.
If we transfer personal information to countries outside of the UK/EEA, we may rely on a decision from the UK Government determining that the country provides an adequate level of protection to the Data Protection Laws. Alternatively, we may rely on appropriate safeguards in respect of transfers of personal information to a country outside of the UK/EEA, for example, by agreeing standard contractual clauses adopted by the UK Government and undertaking a risk assessment in relation to the importing country.
Links to other websites
We would like to send you information about our services which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone or text message (SMS).
We would also like to share your information with the other affiliated Bruntwood companies, so that they may send you information about their services, depending on what you agree with us and/ or our legitimate interests.
You can unsubscribe from marketing at any time by:
contacting us at GDPR@bruntwood.co.uk
using the ‘unsubscribe’ link in emails or by responding ‘STOP’ in texts
Please note that it may take up to 7 days for this to take place.
Where to address questions, concerns or complaints
If you have any questions or concerns or wish to make a complaint about the use of your personal data by Bruntwood, please discuss please contact our Data Protection Manager. We will try our very best to assist you and rectify any concerns or complaints.
The Data Protection Manager can be contacted at firstname.lastname@example.org
In the event you are dissatisfied with our response, you have the right to complain to the Information Commissioner.
The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline number: 0303 123 1113